Privacy Policy

JBS and Maron as independent Data Controllers are committed to protecting Your privacy. JBS and Maron will not collect any personal data about You unless You provide it voluntarily or unless this is required in order to provide our Services or Products or is otherwise required in terms of law. We will process any personal data only insofar as is necessary to provide one or more Services or Products You have requested or otherwise with Your consent. Any personal information communicated to JBS and/or Maron is kept within their own records in accordance with the Data Protection Act (Chap. 586 of the Laws of Malta) as currently in force as well as the General Data Protection Regulation (Regulation (EU) 2016/679).

Definitions

Client/You	Means the Entity or any physical person engaging JBS or Maron to provide the Services/Product. Means J.B.S. Company Limited (C13376), 46, Melita Street, Valletta, VLT 1122 and
JBS/We	Means J.B.S. Company Limited (C13376), 46, Melita Street, Valletta, VLT 1122 and
Maron/We	Maron Limited (C7108) of ‘Marrit Pharmacy’, First of May Street, Fleur-de- Lys, Birkirkara, BKR 1903
Entity	Means the legal person engaging JBS or Maron to provide the Services/Product.
Personal Data	Means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic cultural or social identity of that natural person.
Personal Data Breach	A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Personnel	means the directors, other officers, employees and consultants of JBS & Maron and the officers, employees and consultants of their holding, subsidiary, associated and related companies, firms and entities and their successors in title.
Products	Means those products which JBS and/or Maron have been contracted to provide to the Client.
Services	Means those services in respect of which JBS and/or Maron have been contracted to provide to the Client.
Website	Means the JBS and Maron website at: www.empirepharmacymalta.com and www.marritpharmacymalta.com
Special Categories of Data	Means any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Who is the controller?

The independent Data Controllers are JBS and Maron. Their contact details are as follows:

Legal Basis & Purpose

(a) Services

What Personal Data do JBS and Maron collect?

When purchasing Prescription-Only Medicines, JBS or Maron as the case may be, will collect a prescription by a medical doctor as this is required by law and processed in accordance with Article 9 of the General Data Protection Regulation. We collect a person’s name, surname, identity card number and telephone number when fixing appointments with doctors and other health professionals. We collect a person’s name, surname, gender, address, telephone number, date of birth, health related information and keep test records when requested by customers to provide certain medical tests and Services of a medical nature.

Additionally, We also collect information about the user's web browser (user agent) and IP address for website functionality and security reasons.

(b) Website, Contact Services and Updates/News Services

What personal data do We collect?

You may submit a query through the Website in which case, You would need to give your name, surname and email address. You may also contact Us through our Facebook and other social media pages and in such cases we will process your name and surname as well as any other personal data which we may need to accede to your query or request.

We will collect Your Contact Data and store it in our mailing list. We will use Your Contact Data to send You updates regarding our products and Services offering as this falls within our legitimate interests.

You may unsubscribe at any time by sending an email to info@jbscoltd.com

How long is it kept?

If You engage Maron or JBS to provide the Services You will be entered into our client database and We are then required to keep a record of the information collected for a minimum of five (5) years from the date when the last service was provided by Maron or JBS. In any case, the retention period shall not exceed ten (10) years from the date when the last service was provided by JBS or Maron.

If You register on the Website Your Contact Data will be retained until You unsubscribe.

Whom does Maron or JBS share the data with?

• We will share the data with other persons or entities appointed by Maron or JBS to provide any or part of the Services, namely health professionals, marketing, customer care and administration services providers and Website administrators.
• We will also share Your data with the competent authorities, if We are required to do so in order to comply with any applicable law, regulation or court order.

Transfers to third countries?

Any personal data processed by Maron or JBS is stored on servers in the EU.

Your Rights

• Access to Your information: You may, at any time submit a request to know what information is held in Your regard, if any, and request a copy of same.
• Rectification: Maron and JBS will use their best endeavours to update and maintain the data as accurate as possible within a reasonable time. Maron and JBS assume no responsibility or liability for the accuracy or correctness of any data provided. You may, at any time, submit a request to have any inaccuracies corrected.
• Right to be forgotten: where processing is based on consent, You may at any time request to have any or all of Your details erased. In the event of such a request, JBS and Maron will no longer be able to provide You with updates regarding products and Services Offering.
• Restriction of processing: You may, at any time, submit a request to restrict the processing of Your personal data. Certain restrictions on processing personal data may result in JBS and Maron being unable to provide the products and Services. In such cases, JBS and Maron will terminate the business relationship with You and archive the file. The file will be deleted following five (5) years or ten (10) years (as the case may be) from the archiving and this in line with their regulatory compliance requirements.
• Right to data portability - You may request to receive Your personal data in a structure commonly used and machine readable format and have it transferred to another controller.
• Right to object and automated individual decision-making - where processing is based on the performance of a task in the public interest or based on our legitimate interests, You may object to the processing, however, this is subject to any of our overriding interests including in particular compliance with legal requirements on our part. In such case, We will aim for a result that is mutually satisfactory such as taking Your personal information off the live environment and archiving it for the necessary period to enable us to comply with our legal requirements.

Breach

Any questions or requests for further information should be addressed to info@jbscoltd.com. You are advised that should You feel that We have breached our commitments in terms of this Privacy Policy, You may file a complaint with the Information and Data Protection Commissioner in Malta.

Changes to this Privacy Policy

JBS and Maron regularly improve and add to existing products and services. Because of these ongoing changes, changes in the law, and the changing nature of technology, Maron and JBS’ data practices will be adapted accordingly. If there are any changes to this privacy policy, We will post a notice to this effect on our Website. It is therefore in Your own interest to check the "Privacy Policy" and "Cookies" pages any time You access the Website so as to be aware of any changes which may occur from time to time.

Security

JBS and Maron will use their reasonable endeavours to ensure that adequate and reliable security measures are in place to protect personal data from being lost, misused or illegally accessed.